This EIA examines Notice 2014-58 and what it means. The economic substance doctrine left many unanswered questions for taxpayers on how to apply the rules. Prior IRS guidance failed to address the issues that taxpayers faced, such as what "transaction" means under 26 USC § 7701(o). In October 2014, the IRS issued more guidance in Notice 2014-58, which defines "transaction" and tells us what "similar rule of law" means under 26 USC § 6662(b)(6).
Rufus v. Rhoades is the co-author of Rhoades & Langer, U.S. International Taxation and Tax Treaties, a six-volume treatise published by LexisNexis Matthew Bender. In addition to writing, Mr. Rhoades practices law with a concentration on International Tax matters and in all facets of federal and state income tax matters, including work with the Internal Revenue Service (IRS) and the California Franchise Tax Board on a number of controversial issues. Mr. Rhoades has received the Dana Latham Memorial Award for Lifetime Achievement in Taxation, which was presented by the Los Angeles County Bar Association Section on Taxation, and the Joanne Garvey Award presented by the California State Bar Section on Taxation for substantial lifetime contributions to the field of tax law.
Alexey Manasuev is a Principal with U.S. Tax IQ, a tax boutique firm with offices in Oakville and Toronto (Canada) and Washington, DC (USA). He can be reached at email@example.com. The views and opinions are those of the author and do not necessarily represent the views and opinions of U.S. Tax IQ. The information contained herein is general in nature and based on authorities that are subject to change. Applicability to specific situations is to be determined through consultation with your tax adviser.
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